Sandlin v. Williams

On February 27, 2026, the U.S. Supreme Court delivered its opinion in Sandlin v. Williams. The case originated from a 2023 traffic stop in Ohio, where Officer David Williams pulled over John Sandlin for a broken taillight. Sandlin, an unarmed African-American man, was ordered out of his vehicle and subjected to a pat-down. Despite showing no resistance, he was allegedly thrown to the pavement, resulting in a fractured shoulder. Sandlin sued under Section 1983, claiming excessive force in violation of the Fourth Amendment. Lower courts granted qualified immunity to the officer, concluding that the force did not violate clearly established law. The Supreme Court took up the case to clarify the scope of constitutional protections during routine stops and the limits of qualified immunity.

The Supreme Court reversed the lower courts in a 6-3 decision, holding that the officer's actions were objectively unreasonable and violated Sandlin's clearly established right to be free from excessive force. The Court ruled that qualified immunity does not protect an officer who slams an unresisting person to the ground for a minor infraction when no threat is present. The case was remanded for trial, allowing the excessive force claim to proceed.

Whether a police officer's use of physically forceful measures against a compliant, non-threatening individual during a minor traffic stop constitutes a violation of clearly established Fourth Amendment rights, thereby overcoming the defense of qualified immunity.

The ruling significantly narrowed the application of qualified immunity in excessive force cases, signaling heightened judicial scrutiny over police conduct during routine stops. It prompted nationwide law enforcement agencies to revise use-of-force and de-escalation training, and emboldened civil rights advocates to pursue similar litigation. The decision also reignited congressional debates on police reform legislation, aiming to codify clear standards for constitutional violations.